ML18054B117

Provides Hydrostatic Testing Operability Determinations,Per ASME Section XI Requirements,To Support Continued Operation of Instrumented Insp Technique Testing Performed by Hafa Intl,Inc

ML18054B117
Person / Time
Site:	Palisades
Issue date:	11/13/1989
From:	BERRY K W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8911270009
Download: ML18054B117 (5)

Text

• consumers Power l'DWERIN&

MICHl&AN'S l'RD&RESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 November 13, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -** ASME SECTION XI HYDROSTATIC TESTING OPERABILITY DETERMINATIONS Kenneth W Berry Director Nuclear Licensing Technical Specification 4.3b requires the structural integrity of ASME Class 1, 2 and 3 components be verified and maintained at an acceptable level in accordance with Section XI of the ASME Boiler and Pressure Vessel Code.Section XI requires ASME Class systems be hydrostatically tested once per 10 year Inservice Inspection interval.

Palisades had previously attempted to fulfill this requirement through use of an *alternative inspection technique as permitted by 10 CFR 50.55a(a)(3).

Specifically, Palisades used RAFA International, Inc. (RAFA) and their Topical Report 135(P)A for testing the Main Steam System, Auxiliary Feedwater System and the Service Water System. These three systems were tested during the 1988 refueling outage and at that time were determined to be operable by successful completion of system pressure tests utilizing acoustic emission techniques and leak monitoring devices. By letter dated November 2, 1989, the Nuclear Regulatory Commission (NRC) doubted the validity of the instrumented inspection technique testing which was performed by RAFA and requested the affected licensees to critically review their testing. As a result of this recent action by the NRC these Operability Determinations are provided to support continued operation of these systems until the recent tests have been validated or system hydrostatic tests can be performed to bring these systems into full compliance with Section XI testing requirements.

OPERABILITY DETERMINATIONS Main Steam System The following is a summary of past inservice tests and system hydrostatic tests, nondestructive examinations and Technical Specification examinations which have been perfurmed on the main steam system to comply with ASME and technical specification requirements.

OC1189-0008-NL02 (89 i-1270009 a9l-1l3 ----\ A CA/IS ENE'RGY COMPANY PDR ADOCK 05000a.55 C\' PNU Nuclear Regulatory Commission Palisades Nuclear Plant ASME Section XI Hydrostatic Determinations November 13, 1989

• 2 In 1979, a successful visual examination (VT-2) at 1.25 times lowest relief valve setpoint sy$tem hydrostatic test was performed on a portion of the main steam system. This included the steam lines downstream of control valves CV-0522A and CV-0522B to control valve CV-0521. This test met the Section XI testing requirements for that portion of the main steam system. In 1983, a successful visual examination (VT-2) at nominal operating pressure (900 psia) system inservice test was performed on the entire main steam system. This system inservice test satisfied the Section XI period testing requirements for the main steam system. No system degradations were identified during the performance of this test. In 1985, a successful visual examination (VT-2) at nominal operating pressure (900 psia) system inservice test was performed on the entire main steam system. This system inservice test satisfied the Section XI period testing requirements for the main steam system. No system degradations were identified during the performance of this test. In 1988, a successful visual examination (VT-2) at nominal operating pressure (900 psia) system inservice test was performed on the entire main steam system. No System degradations were identified during the performance of this test. During the current maintenance outage a succussful visual examination (VT-2) at 1.25 times lowest relief valve setpoint system hydrostatic test was performed on the main steam line at control valve CV-0522A to satisfy Section XI testing requirements for replacement for this valve. Welds within this system have been nondestructively examined to satisfy Section XI testing requirements and Technical Specification 4.12 testing requirements.

During the first and second Inservice Inspection intervals there have been 117 nondestructive examinations performed on the 200 circumferential welds within the system. Technical Specification 4.12 requires the high energy main steam line from the containment penetration to the stop valves and feedwater lines from the containment penetration to the f eedwater check valves to be visually inspected for leakage once a week during power operation.

Plant Operations Department personnel have performed these weekly visual inspections since the inception of this requirement.

The following outlines other limitations which could be used to form a basis for relief from the code and which make a main steam system hydrostatic test impractical to perform on our current steam generators.

Technical Specification 3.1.le(4) specifies that a maximum secondary hydrostatic test pressure shall_not exceed 1250 psia.Section XI requires a minimum test pressure of 1249.6 psia. This 0.4 psi band is too narrow to control, considering relief valve and instrument inaccuracies.

OC1189-0008-NL02

'* * . , *'Nuclear Regulatory Commission Palisades Nuclear Plant ASME Section XI Hydrostatic Determinations November 13, 1989 Due to system elevations the maximum test pressure at the top of the test system would be approximately 1224 psia, if test pressure of 1249.6 psia is maintained at the tube sheet of the steam generator.

This value (1224 psia) is well below the Section XI required 1249.6 psia. Therefore, Technical Specifications do not allow Palisades to perform a Section XI hydrostatic test which would satisfy test pressure requirements for the entire system. Technical Specification 3 .1. ld (6) requires the steam generator secondary side pressure never be greater than 350 psi above primary coolant system pressure.

This would require the primary coolant system be heated and pressurized to at least 900 psia. This requirement imposes further difficulties in attempting to control test pressure as heat from the primary side would be transferred to the test system resulting in water expansion.

This expansion further complicates control of test pressure and could result in exceeding the 350 psid limit. 3 The advantage of a hydrostatic test (1249.6 psia) over an inservice leak test (900 psia) is minimal. Hydrostatic test pressure and system design pressure are well below the elastic limits of the piping and components within the system and therefore, no yield or fatigue should result during hydrostatic test conditions.

Therefore, the hydrostatic test is essentially a leak test at a nominally higher pressure.

Conclusion Based on the technical specification and code testing which has been performed on this system which exceeds the minimum code requirements and the small differential (350 psi) between performing a 900 psia system inservice test and a 1249.6 psia system hydrostatic test, this system is considered operable in its present condition.

During the 1990 refueling outage, the steam generators will be replaced and as post-test activity, the system hydrostatic test or an approved alternative testing method of the main steam system will be performed will satisfy the Section XI hydrostatic test requirement for this system. Auxiliary-Feedwater System The following is a summary of past system functional tests, hydrostatic tests and technical specification surveillances which have been performed on the auxiliary feedwater system to comply with ASME and technical specification requirements.

In 1979, a successful visual examination (VT-2) at nominal operating pressures (15 psig for pump suction piping; 1220 psig for pump discharge piping) system test was performed on the entire auxiliary feedwater system. This system functional test satisfied the Section XI period testing requirements for the auxiliary f eedwater system. No system degradations were identified during the performance of this test. OC1189-0008-NL02

• Nuclear Regulatory Commission Palisades Nuclear Plant 4 ASME Section XI Hydrostatic Determinations November 13, 1989 In 1983, Facility Change FC-516 changed high pressure safety injection pump P-66C into auxiliary feedwater pump P-8C. This facility change required a post-system hydrostatic test be performed to satisfy Section XI testing requirements.

The only portion of the auxiliary feedwater system not hydrostatically tested under this facility change was the suction piping to pumps P-8A and P-8B. In 1983, a successful visual examination (VT-2) at nominal operating pressures (15 psig for pump suction piping; 1220 psig for pump discharge piping) system inservice test was performed on the entire auxiliary feedwater system. This system functional test satisfied the Section XI period testing requirements for the auxiliary feedwater system. No system degradations were identified during the performance of this test. In 1988, a successful visual examination (VT-2) at nominal operating pressures (15 psig for pump suction piping; 1220 psig for pump discharge piping) system inservice test was performed on the entire auxiliary feedwater system. This system functional test satisfied the Section XI period testing requirements for the auxiliary feedwater system *. No system degradations were identified during the performance of this test. In the 1988 refueling outage, a successful visual examination (VT-2) at 1.1 times the lowest relief valve setpoint system hydrostatic test was performed on newly installed control valves CV-0736 and CV-0737 to satisfy Section XI testing requirements for addition of these valves to the system. Monthly and quarterly Technical Specification surveillance tests routinely inservice test the auxiliary f eedwater system to demonstrate operability.

During performance of monthly test M0-38 the system, from the pump discharge to the control valves, is pressurized to 1530 psig. During performance of quarterly test Q0-21 the entire system is.placed in operation and flow control to both steam generators is verified.

No system degradation has been identified during performance of these tests. The monthly test has been successfully completed each month for the past 9 years and the quarterly test has been completed each quarter for the past 4 years. This would indicate that the system is capable of performing its design function.

Conclusion Based on the above testing which has been performed on this system only a small portion of this system has not been hydrostatically tested. This system is considered operable in its current condition.

Without reliance on the instrumented inspection technique, the only portion of the system not in full with Section XI code requirements is P-8A and P-8B suction piping. It will be tested during the next scheduled outage. This will satisfy the outstanding Section XI testing requirements for this system. OC1189-0008-NL02

... 'Nuclear Regulatory Commission Palisades Nuclear Plant ASME Section XI Hydrostatic Determinations November 13, 1989 Service Water System The testing which was performed by RAFA on the service water system is of no consequence as a Section XI creditable hydrostatic test was performed in 1984 which satisfiesSection XI and Technical Specification 4.2.2. This system is operable without reliance on RAFA test resuits. The next hydrostatic test is required to be completed by September, 1990. Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector

-Palisades OC1189-0008-NL02 , I 5